Overdrafts have been a hot topic for some time. What is your policy? Is it changing? What feedback have you gotten from examiners? Join us for an in-depth look at the current guidance and best practices.
- Understand regulatory guidance for ad hoc versus automated overdraft programs
- Explain the opt-in/opt-out process required by Regulation E
- Identify the inherent risks of your overdraft program
- Develop effective policy and procedures to support your program
- Effectively report overdraft program details to the board and management
Overdraft programs have always been a hot-button area for examiners – especially for the CFPB, who has had overdraft programs on its radar since its inception. Yet despite the guidance, white papers, and other communications issued by the Agencies, confusion still reigns over which elements apply to the programs individual institutions offer. Regulators want to ensure overdraft program practices do not intentionally or unintentionally result in consumer harm, and you want to protect your institution from UDAAP and other regulatory violations.
This session will review the regulatory guidance in-depth and address best practices for disclosures, fees, accountholder education, and marketing of your overdraft program. It will also review overdraft issues identified through consumer complaints, examinations, and enforcement actions and recommend how to avoid similar missteps.
Dawn Kincaid, Brode Consulting Services, Inc.
Dawn Kincaid began her banking career while attending The Ohio State University. She has over 20 years’ experience in client service, operations, information technology, administrative and board relations, marketing, and compliance. Most recently Dawn served as the Senior Vice President of Operations for a central-Ohio-based community bank, where she created and refined policies and procedures, conducted self-audits and risk assessments, and organized implementation of new products and services. Dawn has served in the roles of Compliance, BSA/AML, CRA, Privacy, and Security Officer. She has led training initiatives, prepared due diligence information, completed a variety of regulatory applications, coordinated internal and external audits and exams, and presented for numerous state associations.